Comcast Has About 76 Lobbyists Working Washington On The Time Warner Cable Merger. This is Why.

How many lobbyists does it take to make a controversial cable merger happen in Washington these days?

Apparently, quite a few. Comcast has registered about 76 lobbyists, spread across 24 firms, to work on its pending $45 billion purchase of Time Warner Cable, according to first quarter 2014 filings with the Senate Office of Public Records.

While some have called it an “army,” Comcast’s lobbying effort is more of a tactical special operations unit. In most cases, lobbyists and firms appear to have been assigned targeted politicians and officials to woo on the merger. In many cases, the lobbyists themselves are former government colleagues of the people they are able to target. And given the sky-high stakes—uniting the top two cable and two of the top three largest internet broadband providers—the company appears to have everyone who matters in Congress covered.

“I don’t think it’s a matter of the complexity of the deals because any number of those lobbying firms are very sophisticated,” says Charles Fried, who served as President Ronald Reagan’s Solicitor General and later co-chaired a task force on lobbying as a Harvard Law School professor, on the number of firms dedicated to the merger. “What it’s about is that many of the lobbying firms have principals or associates who are closely connected to a number—maybe just one—key legislators or bureaucrats or regulators.”

The Comcast team brings together former staffers to some of the most powerful members of Congress together, like Waldo McMillan, a former counsel in Senate Majority Leader Harry Reid’s office, and Malloy McDaniel, Senate Minority Leader Mitch McConnell’s former policy advisor and whip liaison. It includes lobbyists with deep ties to the committees that will evaluate the deal, like Christopher Putala, a former senior staff member of Senate Judiciary Committee. Comcast has also hired lobbyists that are able to target key constituencies that could have a role in the merger. Juan Otero, Comcast’s senior director and policy counsel in its lobbying division and former Committee Director for the National Governors Association, sits on the board of no less than four Hispanic groups, including the Congressional Hispanic Caucus Institute.

A Comcast spokesperson says the high number of firms it employs is due to the complexity of its wide-ranging business. “Comcast and NBCUniversal operate in 39 states, have over 130,000 employees, and function in heavily regulated media and technology businesses,” the spokesperson told TIME in a statement. “It is important for our customers, our employees, and our shareholders that we work with policymakers on the multiplicity of issues that affect our business.”

“With our proposed merger with Time Warner Cable, we have been reaching out to share how the transaction will allow us to continue driving innovation and responding to an intensely competitive environment,” the statement continued. “We will continue to share the public interest benefits of a combined Comcast and Time Warner Cable with the stakeholders participating in the review process, just as we have done throughout prior acquisitions where we have brought new benefits to millions of Americans.”

The 76 lobbyists counted by TIME from public filings all work for firms that cite in their public disclosures work on the merger. But several firms work on multiple issues, and the disclosures do not always identify which lobbyists work on any particular issue. For the purposes of this story, all the lobbyists at firms working on the merger for Comcast were counted. One firm, Gray Global Advisors, was not included in this count because it did not specify work on the merger, even though one of its specialties is mergers with the Federal Communications Commission, which will determine if the deal is in the public’s interest. Two other firms, the Nickles Group and Bloom Strategic Counsel, disclosed that it worked on “issues related to mergers and competition” and “competition issues involving cable and internet service industries” but did not specifically mention Time Warner Cable. They were also left off the list.

Comcast has donated to 32 of the 39 members of the House Judiciary Committee, as well as 15 of the 18 members of the Senate Judiciary Committee, 50 of the 54 House Energy and Commerce Committee and 20 of 24 lawmakers on the Senate Commerce, Science and Transportation Committee, according to Politico. Last year, Comcast spent more than $18.8 million, making it the sixth-highest spender on federal lobbying, according to the Center for Responsive Politics. (Disclosure: TIME magazine is owned by Time Warner, which spun off Time Warner Cable as an independent company in 2009.)

Here is a list of some of the notable lobbyists working for Comcast at lobbying shops that have registered to lobby on the merger: